Will CAP eco-schemes be worth their name? - November 2021 An assessment of draft eco-schemes proposed by Member States
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November 2021 Will CAP eco-schemes be worth their name? An assessment of draft eco-schemes proposed by Member States
CONTENTS
Summary and recommendations 3
1. Introduction 5
2. Information sources and data gaps 7
3. Overview of eco-schemes proposed by Member States 8
4. Assessment of the quality of eco-schemes 10
4.1 Are eco-schemes likely to deliver on the European Green Deal? 11
4.2 Eco-schemes with relevance to climate mitigation 13
4.3 Eco-schemes with relevance to biodiversity protection and restoration 16
Annex 21
For more information, please contact:
Célia Nyssens (celia.nyssens@eeb.org)
Jabier Ruiz (jruiz@wwf.eu)
Tatiana Nemcová (tatiana.nemcova@birdlife.org).
Published in November 2021 by BirdLife Europe, European Environmental Bureau (EEB),
and WWF European Policy Office.
Any reproduction in full or in part must mention the title and credit the above-mentioned
publishers as the copyright owners. All rights reserved.
Stichting BirdLife Europe, the European Environmental Bureau and WWF European Policy Office gratefully
acknowledge financial support from the European Commission and the EU LIFE Programme. The content
and opinions expressed are the sole responsibility of the producers and cannot be regarded as reflecting the
position of the funders mentioned above.
SUMMARY AND
RECOMMENDATIONS
A reformed Common Agricultural Policy (CAP) will enter into force in 2023. The two most impor-
tant changes in this new CAP are on one hand the shift to implementation through national CAP
Strategic Plans (CSP), which are being prepared by EU countries and due for submission to the
Commission by 1 January 2022, and on the other hand, the addition of a new form of direct pay-
ments for environmentally-friendly farming: eco-schemes. In light of the European Green Deal,
many expectations for a greener CAP have been pinned on eco-schemes. Yet, to date, very little has
been known on how EU countries will use this new policy instrument in their CSPs.
This report is the first attempt to catalogue and assess eco-schemes from across the EU (covering
21 Member States), and therefore offers groundbreaking insights into how approximately €48.5 bn
of EU funding1 will be spent over 5 years in the post-2022 CAP. However, the information shared
and analysed in this report is based on draft CSPs, which are highly
Only
19%
likely to change still before their formal submission to the Commis-
sion. In addition, the details on draft eco-schemes were provided by
environmental NGOs and coalitions operating at national level, who
in many cases only received limited information from their Govern-
ment. Nonetheless, we were generally able to judge the quality of draft
of eco-schemes eco-schemes and their potential alignment with the objectives of the
are likely to European Green Deal.
deliver on their As they currently stand, Member States’ proposed eco-schemes will
environmental fall very short of expectations. Only 19% of eco-schemes are deemed
likely to deliver on their stated environmental objectives, 40% would
objectives need significant improvements to be effective, and 41% are completely
misaligned. What’s more, according to our assessment, many well
designed schemes that are likely to deliver are either underfunded or
likely to be outcompeted by less demanding and/or more financially attractive schemes.
The worst examples we identified include:
• eco-schemes for precision farming (supposedly targeting reductions in fertiliser or pesticide
use), when they do not include any benchmarks or requirements for actual input reductions. In
addition to the uncertain environmental benefits of these schemes, the proposal to pay farmers
a fixed rate per hectare for the use of precision farming technologies would benefit the largest
farm businesses, whose economies of scale already make this practice profitable, so public
support is not justified.
• eco-schemes for no-till farming, when they do not have any safeguards on the use of her-
bicides (e.g. glyphosate) nor requirements to apply the other two "pillars" of conservation
agriculture: complex crop rotations and constant soil cover. Not only does no-till have limited
benefits as a standalone practice (except in soil erosion hotspots), but these schemes could
even lead to increases in herbicide use, as the most common alternative strategy to ploughing
for weed suppression.
• eco-schemes for "end-of-pipe" solutions in intensive livestock production, such as feed addi-
tives for dairy cows, certified feeding plans for cattle, or lower than average or reduced anti-
microbial use. These eco-schemes do not tackle the underlying drivers of pollution or exces-
sive antimicrobial use and could become "polluter-gets-paid" subsidies for intensive animal
farming.
1. European Commission, 2021. A greener and fairer CAP
3
• eco-schemes for crop diversification, which is a greening requirement in the current CAP and
was evaluated to have very limited environmental benefits. Crop diversification is part of con-
ditionality in the future CAP, and these eco-schemes are very unlikely to bring any real benefit,
as they do not guarantee an actual increase in crop diversity, nor do they address parcel size; in
other words still allowing for large monocultures.
• eco-schemes for standard grasslands management which do not include any limit on live-
stock density (in regions where it would be environmentally sound to do so), nor the appropri-
ate management requirements to ensure that mowing or extensive grazing delivers the desired
benefits for biodiversity or climate.
In sum, the analysis detailed in this report shows an urgent need for Member States to improve
the design and ambition of eco-schemes before submitting their draft Strategic Plans for approval,
and for the Commission to assess them very critically.
To ensure eco-schemes deliver, and based on the observations made throughout our analysis, we
make the following key recommendations to Member States and the European Commission:
1.1. Pay for practices that contribute to a holistic transition towards more sustainable farming
systems, not for marginal improvements to fundamentally unsustainable models or mere
efficiency gains which disregard other environmental dimensions. Eco-schemes must never
incentivise practices which could cause negative environmental impacts.
2.2. Implement more multi-dimensional eco-schemes and/or incentivise farmers to combine
different eco-schemes on their land. Single practices often do not deliver on their own and
combining several fairly rewarded interventions on a farm can boost synergistic outcomes.
3.
3. Do not trade CAP conditionality for eco-schemes, avoiding in all cases that conditionality
standards are purposefully weakened by Member States, in order to include these farming
practices in their eco-schemes. Conditionality standards must be implemented ambitiously by
Member States and past greening requirements which were found to have limited or no envi-
ronmental benefits should not be supported through eco-schemes.
4.
4. Do not pay for basic farming practices which are already common practice, or which have
unclear or contested environmental benefits. In contrast, maintaining virtuous farming prac-
tices can be remunerated, when the environmental benefits are clear (e.g. High Nature Value
farming or organic farming) and the practices are at risk in the absence of policy support.
5.
5. Ensure eco-schemes have a clear intervention logic and are designed to achieve measurable
improvements, avoiding to fund actions that only require elaborating a plan, keeping a register
of farming activities or applying an innovation, without any commitment to achieving results
on the ground. Scientific evidence should be provided to justify the design and requirements of
the eco-scheme.
6.
6. Eco-schemes must offer fair rewards to farmers, with payments proportional to the expected
environmental benefit of the farming practices supported and the opportunity costs. Eco-
schemes with multiple tiers of commitment and matching payment levels are fairer and more
effective and, therefore, preferable to simple flat-rate eco-schemes.
7.
7. Ensure coherence and synergies with other CAP tools, avoiding eco-schemes that would
weaken or compete with existing agri-environmental measures. Capacity-building actions and
advisory support should accompany the deployment of eco-schemes and other environmental
measures to ensure high uptake and good implementation of the actions supported.
41. INTRODUCTION
Eco-schemes are one of the very few novel instruments available in the toolbox of the future
Common Agricultural Policy (CAP). These schemes for the climate, the environment and animal
welfare will be fully funded by the EU and take the form of yearly payments to farmers who volun-
tarily enrol.
Rather than using CAP direct payments to farmers as just income support, the aim of eco-schemes
is to reward those farmers who manage land in a nature- and climate-friendly way, and to incen-
tivise the adoption of specific farming practices with higher environmental and animal welfare
benefits.
After the failure of the current CAP greening payments, which were the first attempt to use direct
payments for agri-environmental purposes, high expectations are now set on eco-schemes. The
European Green Deal mentions that CAP "measures such as eco-schemes should reward farmers
for improved environmental and climate performance", and the Farm to Fork Strategy says that
they should "offer a major stream of funding to boost sustainable practices"2.
BOX 1. European Green Deal agricultural targets to be achieved by 2030 according to the EU
Farm to Fork and Biodiversity Strategies.
• At least 10% of the EU’s agricultural area is under high-diversity landscape features.
• At least 25% of the EU’s agricultural land is under organic farming.
• Reduce the overall use and risk of chemical pesticides by 50%; reduce the use of more
hazardous pesticides by 50%.
• Reduce nutrient losses by at least 50%; reduce fertilisers by at least 20%.
• Reduce sales of antimicrobials for farmed animals by 50%.
In addition, the European Green Deal includes the headline commitments to reach climate
neutrality by 2050, and to preserve and restore ecosystems and biodiversity. The agriculture
sector is central to achieving these economy-wide objectives.
Nevertheless, the legal framework for eco-schemes - established in the EU regulations for the CAP
2023-2027 - is generally weak and there is a risk that these novel schemes are misused to pay
for very basic and already widespread farming practices, or for new practices with no or limited
environmental benefits. This would not deliver any added environmental value for EU taxpayers’
money, while also failing those farmers who want to be more sustainable and make greater efforts
to improve agricultural practices on the ground.
Whether eco-schemes are likely to deliver on the European Green Deal depends on the decisions
that national governments are currently making in relation to the design of the eco-schemes.
However, there is no legal obligation that links strictly the CAP with the agricultural targets of the
European Green Deal (Box 1). Instead, the CAP regulation includes a vague requirement for each
eco-scheme to cover, in principle, at least two "areas of action" for the climate, the environment,
2. WWF, 2020. Eco-schemes: a key tool to deliver the European Green Deal.
5animal welfare and antimicrobial resistance (Box 2). The European Commission has a key respon-
sibility to ensure the quality of eco-schemes through its ongoing informal exchange with Member
States and, once the draft CAP national strategic plans are submitted at the end of 2021 or early
2022, in the formal review of plans that will take place in 2022.
BOX 2. Areas of action for eco-schemes as described in the CAP regulation for
Strategic Plans
a. climate change mitigation, including reduction of GHG emissions from agricultural
practices, as well as maintenance of existing carbon stores and enhancement of carbon
sequestration;
b. climate change adaptation, including actions to improve resilience of food production
systems, and animal and plant diversity for stronger resistance to diseases and climate
change;
c. protection or improvement of water quality and reduction of pressure on water resourc-
es;
d. prevention of soil degradation, soil restoration, improvement of soil fertility and of nutri-
ent management and soil biota;
e. protection of biodiversity, conservation or restoration of habitats or species, including
maintenance and creation of landscape features or non-productive areas;
f. actions for a sustainable and reduced use of pesticides, particularly pesticides that pres-
ent a risk for human health or environment;
g. actions to enhance animal welfare or address antimicrobial resistance.
This report is focused on eco-schemes but there are, of course, other instruments in the CAP tool-
box (notably conditionality, rural development interventions, investment support and farm advi-
sory services) that must also be used, synergistically whenever possible, to achieve environmental
objectives. This is especially true for Member States with a relatively strong Rural Development
pillar, such as Portugal, Slovenia, Croatia, Austria, Finland, Sweden or Slovakia, all with over 40% of
their CAP budget devoted to Rural Development.
Nevertheless, given the significant share of the CAP budget ring-fenced for eco-schemes (as a gen-
eral rule, 25% of the CAP direct payments, which adds up to approximately €8-9 bn per year across
the EU) their importance cannot be understated. And as a novel tool, they attract more political
attention and concerns about their real capacity to deliver: Will CAP eco-schemes be worth their
name?
62. INFORMATION SOURCES
AND DATA GAPS
As part of the consultations in preparation for the draft CAP national strategic plans, most Member
States have started to share publicly or directly with stakeholders the eco-schemes they are plan-
ning to include in the CSPs. These draft eco-schemes are the basis of the assessment presented in
this brief, which gathers the most recent information available as of mid-November 2021. The list
of draft eco-scheme and sources of information, including links to websites whenever they were
available, are included as an annex.
It must be stressed that these draft eco-schemes - developed in most cases by the technical experts
in the Agriculture Ministries, in ideal situations in consultation with stakeholders - are now the
object of political negotiations, notably with regional agricultural authorities and farm organi-
sations. Therefore, the design of the eco-schemes presented in this brief is still likely to change -
sometimes substantially - before CSPs are finalised and formally approved in 2022.
BirdLife’s, the EEB’s and WWF’s networks of environmental NGOs and national coalitions are
actively following the CAP implementation and were able to provide input for this report in 25 EU
Member States (all except Malta and Luxembourg). Unfortunately, at the time of our assessment,
the governments of three other countries (Romania, Hungary and Greece) have not yet made
any information public on draft eco-schemes, and environmental stakeholders have not had an
opportunity to provide any feedback to them. In one other case, Lithuania, the eco-schemes which
had been presented earlier this year to stakeholders were substantially redrafted in mid-Novem-
ber, making it impossible to include in this brief. Therefore, our assessment is focused on the draft
eco-schemes proposed by 21 Member States3, with the caveat that in many of these countries, the
information available is limited.
Indeed, eco-schemes have been presented in several countries without enough information on the
specific requirements or the payment rates associated, making it difficult to assess their quality
and ambition. Also, information on the number of CAP beneficiaries or the agricultural surface area
targeted is still lacking in many countries, as well as the budgetary allocation for each eco-scheme.
Quite frequently, details on how the CAP conditionality requirements will be implemented in the
Member State have not yet been disclosed and, without this information on the baseline, the added
value of the eco-schemes remains sometimes unclear.
All in all, our EU wide search for details on draft eco-schemes has revealed important delays and
deficiencies in the information made available to environmental stakeholders during this crucial
phase of the design of CAP interventions. With only a few weeks left until CAP national strategic
plans are submitted, it is in many cases not possible or very difficult for stakeholders to engage
and provide feedback on the eco-schemes being designed by Member States. It is very likely that
many of these eco-schemes will be submitted to the European Commission without sufficient prior
public participation and feedback, a limitation that should be taken into account during the assess-
ment and approval process.
3. Please note that Belgium is preparing two different CSPs, one for Flanders and one for Wallonia, so we
assessed a total of 22 different sets of eco-schemes.
73. OVERVIEW OF ECO-
SCHEMES PROPOSED BY
MEMBER STATES
This analysis covers 166 eco-schemes from 22 draft Strategic Plans across 21 Member States.
Typically, countries are planning between 4 and 12 eco-schemes, to cater for different objectives
and farming systems. Only in two cases is this number higher: 17 eco-schemes in Poland and 30
in Slovenia. In a few cases, the number of eco-schemes is lower: this happens in countries that
are planning a multidimensional eco-scheme gathering several interventions under one single
heading.
Five EU countries are proposing multidimensional eco-schemes: Czechia, Estonia, Latvia, Slovakia
and the Netherlands. This type of eco-schemes is generally welcomed by environmental NGOs,
especially when they avoid a flat-rate payment and, instead,
reward farmers in proportion to their efforts. This is achieved,
Only
five
for example, through point-based systems as proposed in the
Netherland. These multidimensional eco-schemes typically
include a mixture of some basic and other more ambitious ac-
tions, sometimes presented as a package, sometimes rather as
a "menu of options". NGOs are calling on governments to raise
the bar for the more basic components of these eco-schemes, countries are
and to ensure that the more demanding interventions are
appropriately rewarded, so they are not sidelined by easier
proposing
options that would be easier to comply with. multi-dimensional
However, the vast majority of eco-schemes assessed are de-
eco-schemes
signed to pay for a single type of intervention, which can com-
prise one or several management requirements. For instance,
in Sweden, the planned eco-scheme for precision farming
covers requirements such as the use of nutrient balance tools, performing soil mapping, estab-
lishing grass cover 2 m around drainage waterholes, doing manure analysis, etc. However, these
actions are not linked to any commitment to reduce the use of fertilisers over time, or to achieving
the result of effectively reducing nutrient losses.
Quite frequently, eco-schemes have been proposed to continue and expand current greening
requirements. This is the case for instance with crop diversification (proposed by Bulgaria, Croa-
tia, Denmark, France, Poland and Slovenia) and for "ecological focus areas", which include catch
crops and nitrogen-fixing crops. The rationale for continuing with these practices is generally very
unclear, as they have been severely criticised in the past by environmental experts for failing to
deliver on their objectives, and by farming stakeholders for relying on a one-size-fits-all approach.
BOX 3. Greening requirements in the CAP 2015-2022
Greening was introduced by 2013 CAP reform and aimed to enhance the environmental
performance of CAP by linking 30% of direct payments to compliance with three "greening
practices": crop diversification, maintenance of permanent grasslands and devoting 5% of
arable farmland to ecological focus areas.
8In 2017, the European Court of Auditors (ECA) published a very critical report on greening1,
in which they criticised the Commission for not developing a complete intervention logic
for the green payment and for not setting clear and sufficiently ambitious environmental
targets that greening should be expected to achieve. While the former criticism should, in
principle, be improved in the new CAP, the lack of clear targets remains an issue, highlight-
ed again by the ECA in relation to the new CAP2.
They also concluded that greening was unlikely to provide significant benefits for the en-
vironment and climate, mainly because of the significant deadweight which affects the pol-
icy. In particular, they estimated that greening led to changes in farming practices on only
around 5 % of all EU farmland. This is due to the multiple exemptions and loopholes intro-
duced during co-decision, which meant that most farmers were able to access greening
payments without changing their practices. This situation is highly likely to repeat itself in
the new CAP, where greening rules were introduced in the conditionality with largely the
exact same derogations and loopholes as previously.
1. European Court of Auditors, 2017. Special Report 21/2017: Greening: a more complex income sup-
port scheme, not yet environmentally effective.
2. European Court of Auditors, 2018. Opinion No 7/2018: concerning Commission proposals for regu-
lations relating to the Common Agricultural Policy for the post-2020 period
Referring back to the "areas of action" which eco-schemes are supposed to contribute to (Box 2),
we have identified a high number of eco-schemes targeting climate mitigation (a), soil and nutri-
ent management (d), biodiversity protection (e), and pesticides reduction (f). Several eco-schemes
could also address water quality concerns (c) through reduced nutrients losses, however, no eco-
scheme is aiming to alleviate quantitative pressures on water resources (c) and we did not identify
any eco-scheme whose primary objective is to improve adaptation to climate change (b), for exam-
ple by supporting a switch to less water-intensive crops. However, many agroecological practices
supported in draft eco-schemes can indirectly contribute to better resilience to extreme weather
events. A very low number of eco-schemes address animal welfare and antimicrobial resistance
(g).
94. ASSESSMENT OF THE
QUALITY OF ECO-SCHEMES
The quality of each of the eco-schemes gathered was assessed by agri-environmental experts in
our network, using a four-category rating system: Good - Likely to deliver, OK - Needs improving,
Bad - Concerning, Awful - Greenwashing.
Overall, the assessment shows that only a small minority of eco-schemes (19%) were deemed good
and likely to deliver on their areas of action, given their current design. A fair share of the eco-
schemes (40%) was judged to be going in the right direction, but still requiring some key improve-
ments (e.g. additional safeguards, changes to proposed requirements or more ambitious target
area) to ensure their environmental benefits.
Worryingly, a significant share of eco-schemes (32%) was deemed of poor quality, meaning that
their current ambition is much too low, with requirements that would sometimes fit better in CAP
conditionality, rather than in eco-schemes. Indeed, these eco-schemes frequently offer rewards
for basic practices or for minimal improvements that will maintain the status quo rather than
improve the climate and environmental performance of farming. At the bottom of the scale, 9% of
eco-schemes were highlighted as amounting to greenwashing (see figure 1). For a low number of
eco-schemes, little more than the name is known, and an assessment was not possible.
Figure 1: Overall Assessment of eco-schemes
9%
19%
Good - Likely to deliver
OK - Needs improving
32%
Bad - Concerning
40% Awful - Greenwashing
A major criteria in judging whether eco-schemes are likely to deliver on their stated objectives is
the level of payment attached to each eco-scheme, i.e. how much a farmer would be paid to apply
a given eco-scheme. However, only 14 countries had shared this information with stakeholders
by mid-November 2021, just 6 weeks before the deadline for submission. Where that information
is available, the national experts we consulted rarely judged the payment levels to be adequate,
with many low-ambition schemes set to over-compensate farmers and absorb a large share of the
budget. Meanwhile, more ambitious schemes will often not provide fair rewards for farmers and
therefore will not be attractive enough to ensure uptake on a large scale.
10In the following sections, we zoom in on the expected contribution of eco-schemes to the European
Green Deal (4.1), as well as more specifically on two crucial challenges facing European agriculture
and requiring urgent action in this decade: climate mitigation (4.2) and biodiversity protection
(4.3). These also correspond to two of the three environmental objectives of the CAP and are con-
nected to most areas of action for eco-schemes.
4.1 Are eco-schemes likely to deliver on the European
Green Deal?
Many of the agricultural targets of the European Green Deal (Box 1) will only be achievable if
well-funded, high-quality eco-schemes are implemented by Member States. While funding in-
formation is still generally lacking, we assessed the potential contribution of the eco-schemes to
these targets by identifying - for each one of them - the main agricultural target pursued.
Generally, the farming practices supported by eco-schemes have the potential to contribute to dif-
ferent targets simultaneously and, actually, single-objective eco-schemes would not be legally al-
lowed according to the CAP regulations (Box 2). Nevertheless, given the design and stated purpose
of draft eco-schemes, in most cases, it was possible to perform this classification.
Based on the data we collected, Figure 2 summarises the number of EU countries, out of the 21 we
reviewed, that are planning eco-schemes with a Good-Likely to deliver or OK-Needs improving
rating on the different Green Deal targets. While some synergies can be expected (e.g. multi-inter-
vention eco- schemes, and schemes for high-diversity landscape features and for organic farming
can contribute to agrochemicals reduction), these low numbers are very concerning.
Figure 2: Number of EU countries/regions with "Good" or "OK" assessment per European
Green Deal target
14
13
11
9
6
4
0
Antimicrobial GHG High Multi- Nutrient loss Organic Pesticides
reduction reduction diversity intervention and Fertiliser farming reduction
landscape eco-scheme reduction
features
11Two countries are proposing eco-schemes aiming to reduce antimicrobial use (Italy and Portu-
gal), however, they were both deemed very poor. Because these schemes are not targeting the root
causes for the use of antimicrobials, there is a risk they could become hidden subsidies for inten-
sive animal farming. In Portugal, for example, a major concern is that the measure only applies
to intensive dairy farming, excluding more extensive forms of animal husbandry. Indeed, these
farming systems are using fewer antimicrobials, but could still improve in practices such as the
use of anthelmintic drugs, which have an important impact on dung fauna.
Only 11 out of the 21 countries assessed are planning to
11
support organic farming through eco-schemes. Using eco-
schemes to support this well-recognised and certified prac-
tice could have been an easy option for all Member States,
but some countries such as Spain or Germany, have preferred
Only
assessed countries
to maintain it under the second pillar. This can also be a
good option provided that a substantial budget is allocated to
it and that it does not prevent organic farmers from access- plan to support
ing eco-schemes for other farm improvements. Most eco- organic farming
schemes for organic farming were generally welcomed by
agri-environment experts, even if the shift from a multi-year
through eco-
to a one-year commitment, and the uncertain budgetary schemes
allocation to organic farming eco-schemes remain a matter
of concern in some countries4.
However, the eco-scheme for organic farming in France was assessed negatively, as this "high-lev-
el certification" eco-scheme will support not only organic production, but also farms holding the
French "high environmental value" certification, on equal footing. This means that farmers would
get the same level of payment for practices with very different standards, breaking the logic of of-
fering economic rewards in proportion with the effort made and the environmental benefit expect-
ed, and reducing the total funds available to support organic farming. As CAP support for organic
farming has been much lower than the demand in the last few years, this is highly problematic.
Regarding the agro-chemical reduction targets, we identified 38 eco-schemes aiming to reduce
nutrient losses and fertilisers, and 14 eco-schemes that primarily target the reduction of pesticides.
The eco-schemes which have been assessed more positively in these areas are those supporting
agroecological practices which reduce the needs for these inputs. In some eco-schemes, such
as those in Germany (for summer crops), Poland or Slovenia, agro-chemicals are not allowed, or
significant reductions are required to enter the eco-schemes. In contrast, Italy is planning an eco-
scheme for integrated crop protection that allows the use of chemical weeding with glyphosate
and which could compete with the organic farming eco-scheme.
Unfortunately, some eco-schemes add very little value to existing conditionality standards. For in-
stance, several countries, including Austria, Denmark, Finland, Poland, and Slovenia, are planning
to pay for growing cover crops over winter. However, there are several conditionality standards for
soils, including one that already establishes an obligation to have a minimum soil cover to avoid
bare soils in sensitive periods. Similarly, many countries are planning an eco-scheme for perma-
nent crops where the only requirement is to have a spontaneous or sown green cover in the alleys.
The main purpose is to avoid tilling these areas, a generalised practice to prevent competition
with the main crop which is frequently applied at the cost of soil erosion. This suggests that many
Member States will interpret the conditionality standards in a minimalistic way, making it easier
to reward anything going beyond that very low baseline.
4. A more detailed assessment of Member States’ plans with regards to organic farming can be found in:
IFOAM Organics Europe, 2021. The ambition gap.
124.2 Eco-schemes with relevance to climate mitigation
The largest sources of greenhouse gas emissions in agriculture are animal farming (especially,
but not only, ruminants), fertiliser use, and farming of drained peatlands, responsible for circa 230,
150, and 150 Mt CO2eq, respectively, in the EU-27. In addition, agricultural land can either emit or
sequester carbon, depending on management practices. Currently, croplands and grasslands on
mineral soil (excluding drained peatlands) are a small source and a small sink, respectively. This
all adds up to about 15% of the EU’s total GHG emissions, which still excludes some agriculture-re-
lated emissions sources (e.g. fuel use), making the agriculture sector a significant contributor to the
climate crisis. Research has shown that agricultural emissions can be strongly reduced5 through
a transition to agroecology, involving a reduction in animal numbers and a shift to less and better
animal protein consumption, which could also significantly increase carbon sinks on agricultural
land6.
Chart adapted from EEB, 2020. A CAP for a climate neutral Europe
5. IDDRI, 2018. An agroecological Europe in 2050: multifunctional agriculture for healthy eating
6. Öko-Institut e.V., 2021. Exploratory Analysis of an EU Sink and Restoration Target
13Table 1: Eco-schemes with relevance for climate mitigation
Number of eco- Number of good or
Practice targeted
schemes OK eco-schemes
Grasslands management (incl. extensive grazing) 21 12
Cover or catch crops in arable and permanent crops 17 10
Fertiliser management (more efficient fertiliser use or substi-
23 4
tution of mineral fertilisers)
Conservation agriculture 5 0
Multiple/undefined practices for soil health and carbon
5 3
sequestration
Agroforestry 4 4
Mulching of crop or pruning residues 3 3
Crop rotation 3 3
Intensive livestock management 2 0
Improvement of drained peatland 1 0
Our analysis of eco-schemes with relevance to climate mitigation (Table 1) shows that few eco-
schemes are focusing on reducing the largest source of GHG emissions: livestock farming and the
imported feed it requires. Despite the overwhelming scientific evidence for the need to reduce herd
sizes in many parts of Europe7, there is only one eco-scheme that is explicitly set up to incentivise
farmers to reduce, albeit timidly, their stocking rates (Belgium-Wallonia). An eco-scheme in Swe-
den is supporting protein crops with the explicit objective of reducing the dependency of feed im-
ports. A few other countries, such as Belgium-Flanders, Croatia or Latvia, are planning to support
nitrogen-fixing crops as part of their eco-schemes, which could also contribute to this objective.
Grasslands management through grazing or mowing is the second most common eco-scheme
across the board. While these may provide important financial support to extensive livestock
farming systems and thereby help maintain carbon sinks, it remains to be seen if the detailed
design of the schemes will deliver additional climate benefits. However, action would have been
needed to incentivise more extensive animal production, and that is generally missing. Some of
the eco-schemes that aim to promote more extensive management, such as in Austria or Spain,
have included very easy to meet requirements in grazing time and periods, which could make
semi-intensive farms eligible. Two eco-schemes targeted at non-extensive livestock management
(Belgium-Flanders and Portugal) are pursuing efficiency improvements, which do not guarantee
environmental benefits, and were deemed concerning eco-schemes by national experts.
Many eco-schemes are aimed at reducing mineral fertiliser use, substituting it with organic fertil-
isers, and improving natural soil fertility through crop rotations, planting of legumes, cover crops,
and mulching of crop or pruning residues. If well designed and implemented, these schemes could
help curb fertiliser use and boost soil carbon content. However, most of these eco-schemes are set
up to reward single practices, whereas reducing emissions from soils and increasing soil carbon
sequestration require a holistic approach to soil management, i.e. a mix of different practices.
7. RISE Foundation, 2018. What is the Safe Operating Space for EU livestock?
14Some countries, Croatia, Cyprus, Portugal and Slovenia, are planning to promote organic fertil-
isers (manure/compost) as an alternative to synthetic fertilisers. While this would in principle be
welcome, none of these schemes, except the Cypriot one, limits the amount of nutrients applied.
Belgium-Flanders, Latvia, Ireland and Sweden, are proposing to pay farmers to apply "precision
farming" (again, without any benchmarking of fertiliser use or target for reduction). Poland is plan-
ning no less than three unambitious eco-schemes for fertiliser management: one to develop and
follow a fertilisation plan (a very basic practice which should certainly not be paid per hectare),
one to plough manure into the soil within a certain time window (also very basic), and one to apply
slurry by other methods than spraying (which causes vast ammonia emissions and is banned in
several EU countries).
BOX 4. Eco-schemes for reducing nutrient losses and fertiliser use
3%
9%
Good - Likely to deliver
OK - Needs improving
35%
53% Bad - Concerning
Awful - Greenwashing
The majority of the eco-schemes aimed at fertiliser and nutrients management were rated
poorly by national experts as they tend to promote techno-fixes (precision farming, use of
nitrification inhibitors) and most lack clear limits to prevent over-fertilisation, or any bench-
marks to ensure more efficient nutrients use. Eco-schemes which were deemed Good or OK
in relation to nutrient and fertiliser management related mostly to the use of nitrogen-fixing
crops, green manures, and crop rotation.
Regarding the third-largest source of emissions from agriculture - farming on drained peatlands
- there is only one eco-scheme: Denmark is planning to compensate farmers to plant grass on
drained peatlands and harvest the grass to remove nutrients so that it can later be flooded with
lower emissions of nutrients and methane. National experts rated this scheme poorly as it does not
seem to require a longer-term commitment guaranteeing that farmers will actually rewet the land.
It is highly disappointing that no country is planning an eco-scheme to support and incentivise
paludiculture (productive use of wet peatlands) on formerly drained peatlands.
In contrast, five countries (Croatia, Latvia, Poland, Slovenia, and Spain) intend to pay farmers to
apply no-till practices ("conservation agriculture"), despite contested evidence of the benefit of no-
till for soil carbon sequestration. Conservation agriculture normally consists of three key practices:
no/limited tillage, complex crop rotations, and constant soil cover. However, none of these eco-
15schemes include other requirements than no-till. In addition, none of these eco-schemes include
safeguards regarding herbicide use, which is often used to replace tilling for weed management.
This makes them very problematic. Finally, only three countries (Germany, Ireland and Poland)
intend to use eco-schemes to support agroforestry or tree planting, a crucial climate mitigation and
adaptation strategy with many co-benefits.
4.3 Eco-schemes with relevance to biodiversity
protection and restoration
Agriculture is the single largest driver of biodiversity loss in Europe8. The most important pres-
sures on biodiversity stemming from agriculture are: abandonment of grassland management,
use of plant protection products, intensive grazing and overgrazing, conversion from one type of
agriculture use to another, drainage, removal of landscape features, diffuse pollution from agricul-
ture and conversion of natural habitats to agriculture. The pressures from agriculture particularly
impact pollinator species, farmland birds and semi-natural habitats.
To improve the CAP’s performance for biodiversity, scientists recommended to protect and restore
landscape features and semi-natural areas, including grasslands, as a top priority9. Studies from
across Europe show that dedicating a minimum of 10-14% of agricultural land to non-productive
features and areas is necessary for birds, and thus other wildlife, to recover10. At landscape level,
around 30% of high-quality wildlife habitat would be required for the large-scale recovery of biodi-
versity11.
Table 2: Eco-schemes with relevance for biodiversity protection and restoration
Number of eco- Number of good or OK
Practice targeted
schemes eco-schemes
Landscape features 26 21
Grasslands management 21 12
Alternative to pesticides (biological or mechanical) 14 7
Habitat improvement or creation 9 8
Crop diversification 6 0
Multiple 4 3
Agroforestry 4 4
Crop rotation 3 3
Our analysis of eco-schemes relevant to biodiversity objectives shows that, in line with scientific
recommendations, the most frequent eco-schemes for biodiversity are aimed at the establishment
and/or management of high-diversity landscape features (26) and the (extensive) management of
grasslands (21). In addition, fourteen eco-schemes address the second most important pressure
from agriculture to biodiversity: the use of pesticides. However, based on the available information
on the design of these eco-schemes, it seems rather unlikely that these measures will bring biodi-
8. EEA, 2020. State of Nature in the EU, Results from reporting under the nature directives 2013-2018
9 Pe’er et al, 2021. The Common Agricultural Policy post-2020: Views and recommendations from scientists
to improve performance for biodiversity. Volume 1 – Synthesis Report
10. BirdLife Europe, 2020. Save Nature-Save farming. Reform the CAP: 3 solutions to beat the biodiversity and
climate crisis
11. Walker et al, 2018. Effects of higher-tier agri-environment scheme on the abundance of priority farmland
birds
16versity back at the scale that is needed and which the EU committed to. Moreover, national experts
have raised concerns that in some cases eco-schemes might jeopardise well-established and
effective multi-annual agri-environment-climate measures by offering less stringent requirements.
Despite eco-schemes for high-diversity landscape features being the single most common type of
measure proposed by Member States, concerns remain that such schemes will not be applied on
a sufficiently large area to make a difference for biodiversity. For example, according to calcula-
tions by our experts, the budget allocated to this measure in Germany can only cover 2.4% of arable
and 4.4% of grassland and in Poland not even 0,3% of arable land. Even if building on the 3 or 4%
included in conditionality - in both cases eco-schemes will fall well short of the 10% target of the
Biodiversity Strategy.
There are also concerns, e.g. in Ireland, that most farmers will be paid for existing landscape fea-
tures of variable quality and there is no focus on improving the quality. Meanwhile, Belgium-Wal-
lonia is considering introducing a cap on the area eligible for support for high diversity landscape
features, which seems to be arbitrary and unjustified on environmental grounds.
BOX 5. Eco-schemes for high-diversity landscape features
5%
15% 23% Good - Likely to deliver
OK - Needs improving
Bad - Concerning
Awful - Greenwashing
57%
Only less than one-quarter of the eco-schemes supporting high-diversity landscape features
were judged by national experts as Good- likely to deliver. More than half of the assessed
schemes are going in the right direction, but important improvements are needed if they
are to deliver. OK or Good schemes include payments for non-productive features and areas
going beyond conditionality requirements, as well as flower strips for pollinators and the
maintenance of agroforestry systems or other farmland habitats. Additionally, nation-
al experts raised strong concerns that many of these eco-schemes have been allocated a
low budget, which will limit the area they could potentially cover and could lead farmers
to favour less ambitious eco-schemes with similar or higher payment levels. When these
schemes also allow for other alternative practices (e.g. nitrogen-fixing crops, following the
failed greening logic of Ecological Focus Areas), this usually led to a poor rating.
CAP conditionality, through GAEC 8, requires each farmer to allocate 3 or 4% of their farm’s arable
land to non-productive elements, including fallow. The lower threshold only applies if some pro-
ductive practices are also included (e.g. catch crops and nitrogen-fixing crops without pesticides),
17in total covering 7% of the farm, or if farmers enrol in eco-schemes aiming to increase non-produc-
tive elements to at least 7% of the farm’s arable land. The table below illustrates the choices made
by Member States who are planning to offer such eco-schemes.
Table 3: Eco-schemes designed to "top-up" GAEC 8
Percentage set in the eco-schemes Are productive elements included?
Belgium -
no % set no
Flanders
Belgium -
up to 9% on all farms no
Wallonia
Bulgaria no % set no
yes (short rotation coppice, catch
Croatia 10% arable crops and green winter cover, nitro-
gen-fixing plants)
8% first two years, then 9%
Czechia no
(part of multi-dimensional eco-scheme)
if 7% reached, conditions of enhanced eco-scheme
Denmark no
apply (max 53%)
Estonia 10% arable yes (nitrogen-fixing crops)
France 7% and 10% (higher tier) no
fallow: up to 9%
top up for flowering strips
Germany no
top up for flowering strips in permanent crops
old grass strips up to 6%
yes (mono-culture forestry and short
Ireland 7% all farms
rotation coppice)
Latvia no % set yes (nitrogen-fixing crops)
Poland 7% arable no
7% arable
Portugal 4% on or next permanent crops or permanent pas- no
tures
5% outside protected areas
Slovakia 7% in protected areas no
(part of multi-dimensional eco-scheme)
Slovenia 6%-20% farm area no
7% on arable
4% on irrigated areas
Spain no
4% permanent crops
2% in rice crops
Sweden 4% flowers strips on arable land no
18Species-rich and/or structurally diverse grasslands are key for preserving biodiversity in Europe
and are frequently part of High Nature Value farming systems. According to national experts, more
than half of the assessed eco-schemes related to grassland management go in the right direction,
but some important concerns remain on stocking rates (e.g. in Belgium-Wallonia) and lack of
rewards for extensive management, as already mentioned in the climate mitigation section above.
From a biodiversity perspective, studies show12 that general or shallow "grassland maintenance"
schemes, which do not take into account the ecological needs of species relying on grasslands, can
lead to the decline of those species, especially in the absence of more targeted agri-environment
schemes. Such concerns have been communicated to national authorities in relation to the pro-
posed eco-scheme in Slovenia, among others.
The use of pesticides is particularly problematic for amphibians, insects, mammals and birds.
While eco-schemes for organic agriculture should be generally beneficial for reducing the use of
pesticides, we have also identified 14 schemes that aim specifically to reduce the use of pesticides
and support alternative pest and weed control methods.
BOX 6. Eco-schemes for pesticides reduction
7%
14%
Good - Likely to deliver
OK - Needs improving
43% Bad - Concerning
36%
Awful - Greenwashing
Half of the eco-schemes targeted at pesticides reduction are deemed concerning or green-
washing by national experts. Ones rated as good or OK normally include a limit on the use
of certain pesticides, such as glyphosate (in Bulgaria), or limit use of all pesticides in certain
cultures (Germany and Slovenia). Cyprus is proposing three schemes aiming to limit the use
of pesticides and herbicides and support alternatives (ploughing, solarisation, and planting
of "pest-trapping" plants), but their efficacy is questioned by experts. Italy, Portugal and
Poland are planning vaguely described eco-schemes for "integrated production" which are
raising strong concerns among national NGOs.
12. Brambilla, M., Pedrini, P., 2013. The introduction of subsidies for grassland conservation in the Italian Alps
coincided with population decline in a threatened grassland species, the Corncrake Crex crex
19In addition to these focused schemes, eco-schemes that support natural pest prevention methods
can also contribute to reducing the need for pesticides. Among those, two important solutions are
landscape features which create habitats for beneficial insects and pests’ predators (discussed
above) and crop rotation, which is a key agronomic practice to control pests and diseases by
disrupting their reproduction cycle. Three eco-schemes are proposed for crop rotation, and are
welcomed by NGOs when they include additional requirements such as long-term rotations or the
inclusion of a leguminous crop in them.
Six eco-schemes are planned for crop diversification, but all were found to be of poor quality.
Diversifying crops across and within parcels is a crucial practice for biodiversity-rich, heterogene-
ous landscapes. However, the eco-schemes proposed for crop diversification barely go beyond the
previous greening requirement, which was found to have little, if any, impact. Indeed, countries are
merely proposing to require several crops to be grown on a farm, without even ensuring that this
effectively increases the diversity, whereas what matters for biodiversity is the size and diversity
of parcels.
Slovakia is the only country proposing an eco-scheme that includes rules on the size of parcels,
accompanied by an obligation to establish a grassy buffer strip in between, though it does not
require different crops to be grown in the different parcels. In addition, crop diversification on its
own is clearly insufficient and it must be combined with crop rotation and non-productive land-
scape elements to ensure benefits for biodiversity. Finally, as crop diversification is included (as an
alternative to crop rotation) in conditionality, the added value of such simple eco-schemes for crop
diversification is questionable.
Interestingly, Italy is planning to provide an additional premium for farms located within Natura
2000 sites, when they apply eco-schemes that can have positive effects on biodiversity (e.g, reduc-
tion of crop protection products, management of grasslands and high diversity landscape features).
A top-up eco-scheme with a bonus payment for Natura 2000 is also planned in Germany, under the
single condition that no new drainage is created.
Despite the clear benefits of agroforestry systems both for biodiversity and climate, we only iden-
tified four eco-schemes supporting agroforestry and the planting of trees on agricultural land. As
the establishment of agroforestry systems may be costly, it would be particularly relevant to look
beyond eco-schemes and assess other tools within the CAP such as investment support measures
to get a full picture of the total level of support for agroforestry.
Greater focus on result-oriented schemes has been highly recommended by scientists13 and exten-
sively piloted in several countries14. Yet, to our knowledge, only two Member states (Germany, Slo-
venia) are proposing a result-oriented eco-scheme for biodiversity. While the German scheme uses
4 indicator plant species, the Slovenian one allows an easier monitoring option, requiring simply
to have flowers with petals of 3 different colours in the eligible area to qualify for the scheme. This
would allow intensive grasslands with no biodiversity value to qualify for this eco-scheme.
Finally, it is worth highlighting some eco-schemes that are targeting certain types of biodiver-
sity very specifically. For instance, an eco-scheme in Slovenia supports the creation of skylark
plots on arable land, constituted by at least one plot of bare soil (>25 m2) per 0.5 ha. In Cyprus, an
eco-scheme supports delayed harvesting of cereals on 20% of the farm to provide food and a safe
breeding environment for birds and other animals.
13. Guy Pe’er et al, 2021. The Common Agricultural Policy post-2020: Views and recommendations from scien-
tists to improve performance for biodiversity. Volume 1 – Synthesis Report
14. European Commission, Farming for Biodiversity, The results-based agri-environment schemes
20ANNEX
Country Name of the eco-scheme Details of the eco-scheme NGO overall assessment Main agricultural EGD target
Farmers can chose from 7 types of catch crops to
grow on arable land after the harvest for diefferent
Greening - using catch crops Nutrient loss and fertiliser
Austria time-spans (from 2,5 months to 5,5 months) start- OK - Needs improving
on arable land 1
reduction
ing in August at the earliest and ending on March
21 at the latest
Requires at least 85% of the farm’s arable land to
Greening - evergreen cover of be covered at all times (i.e. max. 30 days between Nutrient loss and fertiliser
Austria Bad - Concerning
arable land 1
harvesting and catch crop, or catch crop and main reduction
crop)
Requires complete vegetation cover except directly
Erosion protection in perma-
underneath the trunks (at least 60% cover); op- Nutrient loss and fertiliser
Austria nent crops (vines, fruits and OK - Needs improving
tional top-up for use of beneficial organisms and reduction
hops)1
pheromones
Requires at least 120 days of grazing from April to
Animal welfare - grazing for at end of October; no safeguards to avoid intensive
Austria OK - Needs improving GHG reductions
least 120 days1 grassland management with no benefit for biodi-
versity
Belgium - Flan- Extensive permanent pas- No use of pesticides (except for thisle) or inorganic
Bad - Concerning None or Unclear
ders tures 2
fertiliser. Nothing on livestock density.
1. https://info.bmlrt.gv.at/dam/jcr:a7a9d3da-5146-49b9-a9e4-ab08e1c68b7c/01_Interventionen_DZ.pdf
2. https://lv.vlaanderen.be/nl/nieuws/pre-ecoregelingen-2022-ondersteuning-voor-vijf-nieuwe-maatregelen-functie-van-milieu-klimaat
21Country Name of the eco-scheme Details of the eco-scheme NGO overall assessment Main agricultural EGD target
3 possibilities: (1) ES based on management plan
Belgium - Flan-
Carbon storage in soils3 (2) use of C-enriching products like compost and OK - Needs improving GHG reductions
ders
(3) based on soil samples
Former Pillar 2 measure but provides more flexibil-
Belgium - Flan- High diversity landscape
‘Eco-crops’ (N-fixing crops, ...)3 ity for rotation scheme at farm level due to yearly OK - Needs improving
ders features
nature of the measure
Herb-rich grassland considered as yearly crop
Belgium - Flan- Herb-rich productive grass- (temporary grassland). Minimum percentage of High diversity landscape
OK - Needs improving
ders land3 herbs and grasses. No requirements regarding features
pesticides and feritiliser use
Belgium - Flan- Nutrient loss and fertiliser
Precision agriculture3 Details TBD, probably paid per hectare Bad - Concerning
ders reduction
Grassland older than 10/15 years and not ‘renewed’
Belgium - Flan-
Permanent pastures 4
during last 6 years. No other permanent grassland Bad - Concerning GHG reductions
ders
lost at farm level.
Belgium - Flan-
Maintaining organic farming4 Former Pillar 2 measure Good - Likely to deliver Organic farming
ders
Belgium - Flan- High diversity landscape
Annual buffer strips4 Former Pillar 2 measure Good - Likely to deliver
ders features
Belgium - Flan- (1) reduction of claw-desease and (2) reduced
Animal welfare and health4* Bad - Concerning Antimicrobial reduction
ders antibiotics use
3. https://lv.vlaanderen.be/nl/nieuws/pre-ecoregelingen-2022-ondersteuning-voor-vijf-nieuwe-maatregelen-functie-van-milieu-klimaat
4. July 2021 - stakeholder update from administration (not public yet)
* There is indication that this eco-scheme might be moved to Pillar 2
22Country Name of the eco-scheme Details of the eco-scheme NGO overall assessment Main agricultural EGD target
Belgium - Flan- Animal feed and livestock Details TBD, but it will likely include measure on
Bad - Concerning GHG reductions
ders management5 feed additives.
Belgium - Flan- Non-productive areas on Requires a minimum percentage (7% tbc) of farm- High diversity landscape
OK - Needs improving
ders arable land5 land dedicated to non-productive areas features
Belgium - Flan- Former Pillar 2 measure but provides more flexibil-
Mechanical weeding5 OK - Needs improving Pesticides reduction
ders ity due to yearly nature of the measure
Belgium - Wal- Nutrient loss and fertiliser
Soil cover5 No information Not enough info to judge
lonia reduction
Very complex ecoscheme that pays for % of eco-
Belgium - Wal- logical network beyond GAEC 8 on all agriculture High diversity landscape
Ecological Network5 Not enough info to judge
lonia land (after application of three coefficients). Was features
thoroughly watered down since, info out of date.
Initial proposition with payment for up to 3 LSU/ha
Belgium - Wal- Permanent pastures, reward- down to 2,5 LSU/ha in 2027, with increasing pay-
Not enough info to judge GHG reductions
lonia ing lower stocking rates5 ment while extensifying. Good initially, but was
thoroughly modified since, info is out of date.
Payment/ha for 1) legume forage 2) extensive cere-
Belgium - Wal- Nutrient loss and fertiliser
Environment-friendly crops5 als 3) mixed crops. The initial proposal was good Not enough info to judge
lonia reduction
but it is totally outdated now.
5. July 2021 - stakeholder update from administration (not public yet)
23Country Name of the eco-scheme Details of the eco-scheme NGO overall assessment Main agricultural EGD target
Requirement to plant annual crops in the rows of
the perennial crops in order to reduce the mineral
Ecological maintenance of Nutrient loss and fertiliser
Bulgaria fertilisers or maintenance of buffer strips with Good - Likely to deliver
perennial crops6 reduction
natural vegetation; plant protection products not
allowed
Maintaining organic farming
Bulgaria Scheme open to certified organic crop farmers. Good - Likely to deliver Organic farming
(agricultural land)6
Entry conditions: organic certification; min. 1 LU
of supported animals; manage at least 0.5 ha of
pasture area and/or forage areas. Payment only
Maintaining organic farming
Bulgaria for animals for which the farmer manages an Good - Likely to deliver Organic farming
(farm animals)6
agricultural area corresponding to a minimum of
0.3 ha of pasture area and / or areas with fodder
crops per 1 LU.
Payment for maintenance and management of
ecological infrastructure (hedges and trees in line,
Maintenance and improve- standing trees, groups of trees, antierosion tree
High diversity landscape
Bulgaria ment of biodiversity and belts, field boundaries, wet areas, green areas along OK - Needs improving
features
ecological infrastructure6 water courses, terraces); limits on the use of plant
protection products; and ban on operations during
the nesting period.
Extensive maintenance of Requirement to maintain grassland by extensive
Bulgaria permanent grassland with grazing from 0.3 to 1 LU / ha; at least 60 days in the OK - Needs improving None or Unclear
grazing animals6 respective year.
6. https://www.mzh.government.bg/bg/obsha-selskostopanska-politika-2021-2027-g/tematichna-rabotna-grupa/
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